Hong Kong clients are often regional headquarters, trading houses or holding companies, and that shapes how you invoice them. The EDF side is routine: each invoice becomes a Part 2B row with country "Hong Kong", in the currency you invoiced, filed within 30 days from the end of the month. What needs care is making sure the company you invoice is the company that pays, or recording it properly on the EDF when a group company pays instead.
Key takeaways
- Invoice in US dollars or Hong Kong dollars, as your contract says; many Hong Kong businesses are comfortable with either.
- Payments to India travel as international wires. Local Hong Kong payment systems do not reach Indian accounts directly.
- Regional-HQ structures mean the payer is sometimes a different group company. EDF fields 1.15 and 1.16 exist for third-party payments.
- India and Hong Kong have a tax agreement. If a client asks about withholding or residency, involve your CA.
- If your role is arranging supplies between other parties rather than doing the work, check the GST intermediary rules before treating it as an export.
Who you are really working for
A typical Hong Kong engagement might look like this: the contract is signed by a Hong Kong holding company, the work benefits a subsidiary in Singapore or Vietnam, and payment comes from whichever group entity has cash that month. None of that is unusual, but each layer has a consequence.
| Situation | What to check | EDF consequence |
|---|---|---|
| Hong Kong company signs and pays | Nothing extra | Hong Kong in Part 2B; no third party |
| Hong Kong company signs; a group company elsewhere pays | Written confirmation that the payer acts for the client | Name the payer in 1.15, relationship in 1.16 |
| You invoice the Hong Kong company, but services are used by an Indian group company | Place of supply and the "distinct person" condition | Export status may be questioned; ask your CA |
| You source suppliers for a Hong Kong buyer and earn a commission | Intermediary rules | May not be an export of services at all |
The last two rows are the risky ones. Export of services under GST requires, among other things, that the recipient is outside India, the place of supply is outside India, and you and the recipient are not merely establishments of the same person. If any of those wobble, take advice before you invoice. Our glossary entries on intermediary services and third-party payments explain the concepts.
Invoicing a Hong Kong client
| Element | Notes |
|---|---|
| Currency | USD or HKD, as agreed. Stick to one per contract |
| Client name | The exact registered name of the Hong Kong company that contracted |
| Address | The registered or business address in Hong Kong |
| Description | Specific: "Market sizing study, ASEAN cold-chain logistics" |
| SAC code | As agreed with your CA, for example 998371 for market research |
| LUT wording | "Supply meant for export under LUT without payment of IGST" |
| Bank details | Your Indian bank's SWIFT code, account number and name |
| Payment terms | Specify who bears transfer charges |
Hong Kong companies are used to English-language invoices in international formats, so a clean export invoice from the free export invoice generator works well.
How the money travels
Hong Kong has efficient local payment systems, but they are domestic. A payment to your Indian account normally goes as an international SWIFT wire, often in US dollars, sometimes through an intermediary bank. Your AD bank is the Indian bank where it lands.
When the payment arrives, your bank's FIRA or advice will show the remitter. If that is a group company rather than your contracting client, keep the client's written confirmation on file and make sure your EDF reflects the third-party payer.
The tax agreement
India and Hong Kong have a tax agreement designed to avoid double taxation. Whether it affects your fees depends on the nature of the service and the client's position. If a Hong Kong client mentions withholding tax, asks for a tax residency certificate, or wants a "net of taxes" clause, talk to your CA before agreeing. We do not set out Hong Kong tax rules here.
A worked example
Arcadia Data Labs Pvt Ltd in Chennai provides market research and data analysis. In January 2027 it raised three invoices to Hong Kong-linked clients:
| Invoice | Contracting client | Payer | Currency | Amount |
|---|---|---|---|---|
| AD/27/005 | Harbourline Holdings Ltd, Hong Kong | Harbourline Holdings Ltd | USD | 12,400 |
| AD/27/011 | Jadeport Trading Ltd, Hong Kong | Jadeport Vietnam Co. Ltd (group company) | USD | 4,800 |
| AD/27/016 | Kowloon Lantern Ltd, Hong Kong | Kowloon Lantern Ltd | HKD | 36,000 |
The January EDF is due 2 March 2027 and lists all three in Part 2B with country "Hong Kong" and the respective currencies. Field 1.17 says Hong Kong.
The Jadeport invoice needs extra care. Arcadia obtained an email from Jadeport's Hong Kong finance team confirming that the Vietnam company would pay on its behalf. In field 1.15, Arcadia named Jadeport Vietnam Co. Ltd, and in 1.16 described it as a group company paying on behalf of the client. Before filing, it asked its bank whether it wanted that confirmation attached; the bank asked for a copy.
The Harbourline invoice is above ₹10 lakh, so on payment Arcadia will provide the invoice, FIRA and matching instructions. The other two can go into its quarterly realisation declaration.
Several currencies on one EDF
Hong Kong clients invoiced in HKD sit comfortably on the same EDF as US dollar or euro invoices. Each Part 2B row carries its own currency and amount, and field 1.22 converts the total to rupees at a consistent rate. Our article on multi-currency exporters walks through the arithmetic.
Purpose codes
Check the purpose code on every FIRA. Research and analysis work might sit under P1007 (advertising, trade fair, market research); consultancy might be P1006. Confirm the code with your bank and use the purpose code finder to prepare. This is general information, not legal or tax advice.
Frequently asked questions
Should I invoice Hong Kong clients in HKD or USD?
Either can work, and many Hong Kong businesses are comfortable paying in US dollars. Agree the currency in the contract and use the same currency in your EDF Part 2B row.
A group company in another country pays for my Hong Kong client. Is that allowed?
Third-party payments are anticipated by the EDF, which has fields 1.15 and 1.16 for the third party and its relationship. Get written confirmation from your client, record it on the EDF and ask your bank whether it needs a copy.
Which country do I enter on the EDF?
The country of the service recipient you invoiced, so Hong Kong if your client is a Hong Kong company. A third-party payer in another country does not change the recipient's country.
Is sourcing work for a Hong Kong buyer an export of services?
Not necessarily. If you arrange supplies between other parties for a commission, GST intermediary rules may apply and the service may not qualify as an export. Have your CA review the contract.
How long do I have to receive payment from a Hong Kong client?
Nine months from the invoice date for foreign currency invoices. If a payment will be late, ask your AD bank for an extension with reasons before the deadline.
Bottom line
Hong Kong work is easy to invoice and pay; the care goes into who signs, who pays and what you actually do. Record third-party payers properly, check intermediary risk, and file one EDF a month. Build it with our free EDF form generator.
This guide is general information for Indian businesses, not legal or tax advice. Rules and bank processes change — confirm specifics with your AD bank or chartered accountant.